OSHA Clarifies the Question of Multiple Country Info on one Label

Written By: Atanu Das on Monday, February 18, 2019

In the letter, a company has the following scenario:

Scenario: Your company has a chemical that is packaged in pre-printed bags, which are made to stock and then shipped around the world. In order to reduce relabeling and repackaging, you would like the chemical label to include the chemical hazard classifications for the United States (U.S.), European Union (E.U.), and China in clearly marked separate boxes.

Question 1: Is it acceptable to have other countries' hazard classifications in addition to the U.S. HCS 2012 classification, on a chemical product label?

Response: The HCS 2012 requires chemical manufacturers, importers, or distributors to ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged or marked with the following information: product identifier; signal word; hazard statement(s); precautionary statement(s); and pictogram(s); and name, address and telephone number of the chemical manufacturer, importer, or other responsible party. 29 CFR 1910.1200(f)(1). The HCS 2012 does not prohibit a manufacturer or importer from adding supplemental information to a label, as long as it does not lead to unnecessarily wide variation or undermine the required label information. Section C.3.1 of Appendix C to HCS 2012 explains that supplementary information may only be added to a label if it provides further detail and does not contradict or cast doubt on the validity of the required information. Therefore, if the other countries have hazard classification information that contradicts or casts doubt on the HCS 2012 information, it is not permitted to be on the label. 

OSHA makes clear that any conflicting or confusing information meant to be conveyed on labels and SDSs must not be used as this may be in violation of the hazard communication standard.

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